MEMORANDUM

TO:		Public Record for the NPDES Electronic Reporting Rule
		EPA Docket Number EPA-HQ-OECA-2009-0274 (www.regulations.gov)	

FROM:	 Carey A. Johnston, P.E.
      USEPA/OECA/OC
            ph: (202) 566 1014
      johnston.carey@epa.gov

DATE:		17 November 2011

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SUBJECT: 	Description of the PCS and ICIS-NPDES [DCN 0008]
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      A.    The Permit Compliance System (PCS)
      
      EPA uses the Permit Compliance System (PCS), a national data system developed in 1982, to support the NPDES program. PCS, which is managed by the Office of Enforcement and Compliance Assurance (OECA), is a critical information system for EPA's Office of Water and OECA. PCS tracks NPDES permit issuance, permit limits, self-monitoring data, enforcement and inspection activity for NPDES facilities regulated under the CWA. PCS currently tracks data for 16 states. The data from 34 other states, 19 territories, 2 tribes and 10 EPA Regional offices that had previously been in PCS were migrated to ICIS-NPDES, the modernized system. PCS, identified as a mission critical system for the Agency, is one of the Agency's largest and most complex systems, given the large number of transactions and the variety of information sources for hundreds of thousands of NPDES permittees. The NPDES Discharge Monitoring Reports (DMRs) that the permitting authorities collect and process constitute the second largest data collection effort within the federal government, accounting for close to 30 million records. 
      
      The PCS Policy Statement (as amended) identified the data elements that were expected to be entered or otherwise provided by the states to EPA through PCS. This policy statement and accompanying data requirements allowed PCS to function for many years as a useful management tool for the NPDES program, providing EPA with a nationally consistent set of facility-specific NPDES information, particularly for major facilities.
         
      B.    The NPDES component of the Integrated Compliance Information System (ICIS-NPDES) 
      
      The Integrated Compliance Information System (ICIS) serves as the repository for multi-media compliance and enforcement data at the federal level. The development of ICIS was divided into three phases. The first phase focused on developing a system to integrate federal enforcement and compliance activities. The second phase focused on the incorporation of the NPDES program specific requirements, thus creating the ICIS-NPDES component which is intended as a replacement national NPDES data system for PCS. The third phase, under discussion, may add air-related program-specific requirements. 
      
      C.    Why the Change from PCS to ICIS-NPDES?
      
      When EPA and the NPDES-authorized states developed the Water Enforcement National Data Base (WENDB) list of data elements for PCS, NPDES agencies were focused on the control and reduction of pollutant discharges from the identified point sources of pollution that were priorities for national attention at the time, specifically, major dischargers. The NPDES program has evolved considerably since then. EPA now recognizes the need to better quantify and address the environmental impacts from nonmajor point sources (including wet weather sources) as well. The changes in the focus of the NPDES program implementation necessitate change in the data to be tracked and in the areas in which program oversight is conducted.
      
      Given the significant advances in computer technology in the past twenty years, the underlying database technology supporting the PCS data system has grown increasingly outdated and unsupported, making it impractical to upgrade and difficult for EPA and NPDES-authorized states to maintain. The PCS data system is also not capable of handling the increase in the expanded NPDES universe. EPA and states modified their NPDES data systems to address new program requirements, but not necessarily in a nationally consistent or methodical manner. Without a systematic approach, difficulty obtaining the necessary data to make strategic program decisions from each state and EPA Region, including data needed to respond to requests received by EPA, hampers EPA's ability to provide timely responses to both Congress and the public on pollutant discharges and trends of national or regional significance. This lack of timely access to nationally consistent NPDES information from the states has undermined the Agency's capacity to conduct program oversight and to make the best-informed program management decisions.
      
      EPA has worked closely with its state partners in an effort to modernize PCS and eventually replace it with ICIS-NPDES. ICIS-NPDES was designed to improve EPA's and states' ability to track and manage information related to all NPDES sources. The new ICIS-NPDES ensures that the more traditional NPDES information remains available, accessible, and useful, and also provides means to track and access other NPDES information that was not historically available in PCS.
      
      There are substantial benefits derived from a more modern NPDES data system. Through this rule's requirement for electronic reporting of NPDES information, ICIS-NPDES will capture information for all permitted NPDES sources, improve NPDES agencies' capacity to evaluate compliance, perform watershed analysis, evaluate trends in NPDES program implementation, and report to Congress. ICIS-NPDES would continue to support the public's access to information through Agency web sites providing a more complete picture of the NPDES program for EPA, its state partners, Congress and the public.



